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Transfer pricing services



Cross-border business transactions with related associated parties have to be established in accordance with the internationally accepted arm’s-length-principle and must be documented in line with domestic tax rules. Only if transfer pricing is understood as a continuous process  will the taxpayer be able to minimize the related tax risks in the long run without putting  their business model – as a base of corporate success – into question.

Transfer pricing has developed to a task of continuous risk management and control, whereas for compliance obligations, such as the preparation of documentation, cost and process efficient approaches are available in the meantime.

Your business model constitutes the starting point of any transfer price setting. Our consulting approach is marked by the objective to support you in the implementation of your business ideas and goals.

Based on our long-term experience in transfer pricing, both within Lithuania and abroad, we support you in the design of operative efficient transfer pricing structures as well as in the reduction of tax-related risks.

Insofar, the business area Transfer Pricing of Rödl & Partner has been strengthened on an international level by more than 80 transfer pricing specialists in more than 32 countries.

Our strength – your benefit: more than 80 transfer pricing professionals in more than 32 countries.


Rödl & Partner in Lithuania:

We advise and support you with our industry expertise in the development of a transfer pricing strategy tailored to your business.  Our services include the entire spectrum of transfer pricing advice and, in such context, in particular:

  1. Planning, creation and implementation:
  • Analysis of the existing transfer pricing systems under risk considerations
  • Development of a transfer pricing system concept and choosing a method
  • Implementation of transfer pricing systems in tax and legal terms
  • Establishment of group-wide transfer pricing guidelines
  • Consideration of related tax issues (e.g. questions about staff posting, permanent establishments or, customs etc.)
  • Support in (national) special topics (e.g. business restructurings, national regulations against BEPS).


2. Documentation and country-by-country reporting:

  • National coordination and preparation of transfer pricing documentation (e.g. Master file, Local file)
  • International documentation concepts (e.g. OECD Masterfile Concept)
  • Preparation of benchmark studies and database analyses
  • Annual financial updates of benchmark studies and database analyses
  • Preparation, conversion and analysis of Country-by-Country Reports.


3. Audit and dispute resolution:

  • Identification of transfer pricing risks (”stress tests”)
  • Support during domestic and foreign tax audits
  • Advice on issues related to appeal proceedings
  • Support during arbitration proceedings
  • Support during mutual agreement procedures
  • Consulting in APA (Advanced Pricing Agreements).


4. Special topics:

  • Transfer of functions
  • Permanent establishments
  • Cost allocation systems
  • Financing
  • Valuation of intangible assets
  • Determination of license fees
  • Determination of interest rates
  • Transfer pricing-due diligence
  • Structure of an operative transfer pricing management.


Contact Person Picture

Nora Vitkūnienė

Head of Tax Department

Associate Partner

+370 5 212 35 90

Send inquiry

Contact Person Picture

Andrius Briedis

Tax and Transfer Pricing Consultant

+370 5 212 35 90

Send inquiry

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